By operating with neglect, disorganization and a level of carelessness that is staggering, BLM turns everything into “roundup vs no roundup,” accuses advocates of “not understanding,” increases volatility among stakeholders, perpetuates an infuriatingly childish cycle.

They did it again. 

Back in 2016, ten-years ago, BLM was working on specific management plans for Herd Management Areas (HMAs). They simply stopped with no explanation.

Instead of completing the HMAP for the South Shoshone HMA that was being drafted in 2016, BLM dropped the ball. Now we get a short gather plan that claims to be an HMAP and a gather plan for 4 HMAs, an additional HA, and all the acres in between.

Basically BLM waited until pressure from livestock, existing and new mining, growing recreation, increasing population of wild horses, literally turned into a powder keg before they “strike the match” causing an untenable reality where now a “clock is ticking” to attempt to have any civil conversation towards a fair and honest plan.

BLM has finalized the Callaghan Complex HMAP and Gather plan. You can access documents on the BLM site here. BLM has changed their website and you can no longer read documents online and an automatic download begins. So if it seems like you did not access the document, check your downloads.

We are already seeing misinformation spread on social media. Finalizing a plan is NOT the same as putting it on the roundup schedule. There is no scheduled roundup of “over 5000 wild horses” from Callaghan… yet. 

Just as with the Carter/Buckhorn/Coppersmith EA that was approved last year (that most of you are familiar with) approving the EA does not automatically place the area on a roundup schedule. The approval of an EA begins the appeal period.

Father and son (with a curly mom and the young colt obviously carries the code from her)

When BLM finalizes an Environmental Assessment (EA) and issues a Decision Record, it starts an appeal period, not an immediate roundup. During this time, members of the public and organizations can file administrative appeals and stay petitions. Using this appeal process is crucial because it “exhausts administrative remedies,” which is usually required before you can challenge the decision in federal court.

Finalizing the Callaghan EA does not automatically put the complex on the helicopter gather schedule. BLM must still line up corral space, transport, contractors, and funding, and then add Callaghan to a published gather schedule. Helicopter gathers in Nevada typically run from July 1 through the end of February.

Because of these timing and logistical realities, there is still a meaningful window to make an impact. Strong, well‑grounded administrative appeals now can shape or slow the agency’s plans. If BLM pushes ahead toward a large‑scale roundup, having used the appeal process puts advocates in a much stronger position to seek relief in federal court.

BLM’s new “Herd Management Area Plan” (HMAP) for the Callaghan Complex in Nevada looks, on close inspection, much more like a long‑term roundup plan than a true herd and habitat management plan.

What an HMAP is supposed to be

BLM’s own Wild Horses and Burros Management Handbook (H‑4700‑1) describes HMAPs as implementation plans that translate broad land‑use plans into specific, on‑the‑ground management for each herd or herd complex. The handbook says HMAPs should:

• Set short‑ and long‑term detailed management and monitoring objectives for the herd and its habitat.​

• Identify herd objectives (clear and specific: numbers, sex and age structure, genetic health, behavior, foaling season).​

• Identify habitat objectives and projects specifically (forage, water, cover, and specific improvements such as water developments, fences, vegetation treatments).​

• Include a clear monitoring framework that links what is measured on the land to those objectives.

• Fit within, or trigger changes to, the broader land‑use plan when needed.​

In other words, an HMAP is supposed to be a comprehensive, interdisciplinary plan for both the horses and the land—not just a schedule to trap and remove animals with vague terms asserting management values. 

A gather EA is the NEPA document that analyzes a specific roundup proposal so the agency can decide if, how, and when to conduct gathers and removals.

BLM gather EAs are supposed to:

• Describe the proposed gather and any action and no‑action alternatives (how many horses, what methods, over what timeframe, how often, and what will happen to removed animals).

• Analyze site‑specific environmental impacts of those alternatives on key resources (wild horses, vegetation, soils, water, wildlife, cultural resources, socioeconomics, etc.), and disclose mitigation and standard operating procedures for humane handling and reduced impacts.

• Explain how the gather fits within existing land‑use plans, AML decisions, an HMAP (if there is one) and other laws and policies, and provide a basis to decide whether impacts are “significant” enough to require a full Environmental Impact Statement or whether a Finding of No Significant Impact and a Decision Record are appropriate.

In other words, a gather EA is supposed to be a focused, site‑specific environmental analysis of a roundup operation—not a complete, long‑term management blueprint for the herd and its habitat, which is what an HMAP is meant to provide.

What the Callaghan “HMAP” actually is

The new Callaghan document is titled a “Herd Management Plan Gather Plan Environmental Assessment,” which already signals that BLM is combining two things: a long‑term herd management plan and a gather (roundup) plan.​

Inside, most of the detail is about:

• Immediate and follow‑up helicopter and bait trapping gathers.​

• Removing (about 5000) wild horses to the low end of an old Appropriate Management Level (AML) of 323–552 animals across the entire 1.1‑million‑acre complex, leaving only a relative handful on the range.​

• Using fertility control, changing sex ratios to about 60% males, and adding sterilized mares or geldings to create partially non‑reproducing herds.​

• Standard gather and holding procedures and logistics.

• Refusing to analyze anything else​ with claims of “outside the scope” (the same as every other gather EA)

All of the above are in the “gather plan” category.

In this EA, the “HMAP language” is pushed into Appendix XIII and summarized in a single “HMAP matrix” table. That table mostly repeats gather‑related ideas (manage within current AML, apply contraceptives, collect genetic samples) and offers a few broad habitat statements (limit use to 40% of annual plant growth, maintain existing water developments).

On review: Basically it seems BLM short changed analysis requirements for even a traditional roundup plan alone because the gather plan would exceed some new page limit guideline for an EA instead of switching to the more appropriate EIS track. 

What is largely missing is what the handbook emphasizes: clear, detailed herd objectives, concrete habitat projects and priorities, and a robust monitoring and adaptive‑management scheme and disclosing exactly where analysis was done to create things like AML and if it was not done, completing that process.

This is why we say this document is a gather plan that has simply been given the HMAP label (and why we are really upset that BLM dropped the ball in 2016 and, no matter how many years we kept asking for them to resume the work, refused to answer). 

What comes next?

When BLM finalizes an Environmental Assessment and issues a Decision Record, the clock starts on the appeal period. If you’re thinking about appealing, your first task is to carefully reread the EA, Decision Record, and the agency’s response to public comments. As you read, look for where BLM was required to analyze something (for example, how it set AML, how it considered wildfire fuels, how it weighed alternatives) and ask: did they actually do the analysis they say they did, and is it specific to this herd and landscape or just boilerplate?

Next, compare your own prior comments to how BLM responded. If you raised issues like fire, habitat, AML, or alternatives, check whether the agency answered those points directly and with real reasoning, or brushed them off with vague or generic language. Strong appeals usually point to concrete gaps: missing data, ignored science, reasonable alternatives that were dismissed without real analysis, or misstatements about what the law or handbook requires.

Finally, before the appeal deadline, outline your key arguments in plain language: (1) what decision you are challenging, (2) what legal or policy requirements apply (NEPA, wild horse regulations, the handbook), (3) how BLM’s analysis or responses fell short, and (4) what you want the reviewing body to do (for example, require a new or supplemental analysis before implementing the plan). Having that clear structure and tying each point back to specific pages or statements in the EA and responses will put you in the best position to file a focused, effective appeal.

Usually the Decision Record gives details on how to file an appeal. In this case BLM simply says: “If you wish to appeal this decision, it may be appealed to the Interior Board of Land Appeals, Office of the Secretary, in accordance with 43 CFR part 4.” But they provide you no additional info. Here is a link. 

For BLM decisions like a wild horse EA and Decision Record, the standard deadline is 30 days from the date you receive or are deemed to have received the decision.

• The exact deadline and where to file are stated in the “Right of Appeal” or similar section at the end of the Decision Record or cover letter. Always read that language carefully; it controls your case. (In this instance BLM gives you literally no language specific to this EA at all. Here is a link to the CFR)

• “Thirty days” means your written Notice of Appeal must be received (or postmarked, depending on the instructions given) within that 30‑day window. If you miss it, you generally lose the right to challenge the decision administratively.

• If you plan to ask for a stay (to pause implementation while the appeal is pending), the stay petition usually must be filed at the same time as, or very soon after, your Notice of Appeal, so you should prepare both before the 30‑day period runs.

  Above: Some of you will remember our team was in the right place at the right time last spring while we were tracking all the livestock out in the Callaghan Complex to stop what could have been a tragedy after BLM failed to fix cattle guards and yet was aware of a helicopter survey. (Read the story here)

  Our team is reviewing the document, meeting with our attorney, beginning to formulate our arguments. (WHE has engaged our attorneys for the Appeal period as we know this case will almost certainly land in federal civil court as BLM is unlikely to address any mediation with advocates even though traditionally they do  so with livestock permittees all the time). We do need your support to pay those bills and donations are matched dollar-for-dollar through 2/21.

  We will talk more about this area in future articles. BLM simply did nothing for a very long time. Not when it hit 1000 wild horses. Not when it hit 2500 wild horses. Not when the population reached 4000 wild horses. But now they claim an AML set, not in data analysis but an agreement in the 1980s is what they need to reach?

  This EA says 323–552 wild horses is all that can be sustained across all HMAs in the complex with a gather area of approximately 1,145,515 acres? Please note that we have done this review back in 2016: No planning document has ever set a data-based AML for the herds in this complex. 

  In future articles we will talk more specifically about BLM failures in this EA. Right now we need to work quickly for these herds.

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  Every mile we travel to cover roundups or assess a herd, every court case we bring, every win, every action we take is only possible because of your support.